Howe v. Astrue, 4:11-cv-00917

Howe timely sought judicial review of a final SSA decision denying his Title XVI disability benefits claim.
The Commissioner denied benefits after the ALJ’s evaluation, and Howe challenged the decision in this Court.
The Court reviews the Commissioner’s decision to determine if it is supported by substantial evidence in the record as a whole.
The standard of review requires not reweighing evidence but affirming if substantial evidence supports the Agency’s findings.
The Court grants deference to the ALJ’s findings and upholds the decision if a reasonable mind could accept the evidence as adequate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Commissioner’s determination of not disabled is supported by substantial evidence	Howe contends the record lacks substantial support	Astrue maintains the record contains substantial evidence supporting the ALJ	Yes; substantial evidence supports the decision
Whether the burden-shifting framework was properly applied	Howe argues the burden shift was not satisfied	Astrue asserts proper application of the burden-shifting framework	Yes; framework properly applied
Whether the Court should reweigh the evidence	Howe asks for reweighing of the evidence	Astrue argues Court may not reweigh and must defer to the ALJ	No; Court defers to the ALJ’s findings with substantial evidence

Gragg v. Astrue, 615 F.3d 932 (8th Cir. 2010) (standard for substantial evidence review)
Fountain v. R.R. Retirement Bd., 88 F.3d 528 (8th Cir. 1996) (substantial evidence standard applied to administrative decisions)
Craig v. Chater, 943 F. Supp. 1184 (W.D. Mo. 1996) (court not to reweigh the evidence; deferential review)
McClees v. Shalala, 2 F.3d 301 (8th Cir. 1994) (deference to agency findings when supported by evidence)
Roe v. Chater, 92 F.3d 672 (8th Cir. 1996) (administrative decision not to be reversed for contrary evidence where substantial evidence supports it)
Richardson v. Perales, 402 U.S. 389 (1971) (establishes substantial evidence standard)